PFAS terminology can create confusion in food-packaging procurement. “No intentionally added PFAS” is a formulation statement: it addresses whether PFAS were deliberately added for a function. It is not the same as proving that no PFAS molecule is detectable at any concentration.
What are PFAS?
Per- and polyfluoroalkyl substances are a broad group of fluorinated substances. Certain PFAS have been used because they can provide oil, grease, water, heat, or chemical resistance. Government of Canada materials identify food packaging among the applications in which PFAS have been used, including as grease-proofing treatments.
The group includes many substances with different identities, uses, analytical behaviours, and regulatory statuses. A purchasing specification should therefore define its scope instead of relying on “PFAS-free” as an undefined label.
What “no intentionally added PFAS” means
The phrase generally indicates that PFAS are not deliberately introduced into the product formulation to provide a function. A useful supplier declaration should state the product or material covered, the information basis, relevant formulation scope, date, and responsible organization.
The statement may be supported by formulation records, supplier declarations, raw-material information, process review, or other documentation. The appropriate evidence depends on the supply chain and the buyer’s risk requirements.
What the wording does not prove
“No intentionally added” does not automatically establish:
- that analytical testing will report a non-detect for every PFAS;
- that the product meets every jurisdiction’s definition or threshold;
- that recycled or upstream inputs contain no trace background PFAS;
- that processing equipment, water, packaging, or transport cannot introduce contamination;
- that the product is certified, compostable, recyclable, or approved for food contact;
- that the formulation will remain unchanged without an agreed change-control process.
The Government of Canada’s State of PFAS Report notes that untreated paper products made from recycled feedstock can contain detectable PFAS because treated paper may enter recycled-paper streams. This is one reason absolute wording requires careful definition and evidence.
Which documents should buyers request?
A proportionate documentation package
- Scope statement: product codes, components, formulations, coatings, inks, adhesives, and relevant process aids covered.
- Supplier declaration: signed and dated wording describing the basis for no intentional addition.
- Material information: applicable specifications or supplier records for key inputs.
- Testing information: if required, the method, analyte list or total-fluorine approach, detection limits, laboratory, sample identity, and date.
- Change control: notification expectations for material, formulation, supplier, or process changes.
- Food-contact information: documentation specific to the intended food and conditions of use.
Not every procurement decision requires the same package. A screening discussion may begin with a supplier declaration, while a national program or regulated customer may require a broader technical and legal review.
How analytical testing fits
Testing can add information, but a result is meaningful only when the method and scope are understood. Targeted methods look for specified compounds. Broader fluorine measurements may indicate total or organic fluorine but do not necessarily identify which substances are present or why.
Buyers should record the sample, laboratory, preparation, method, analytes, detection or reporting limits, result units, and decision threshold. A non-detect means the reported analytes were not detected above the stated method limits in that sample; it does not prove universal absence.
PFAS and food-contact review are separate
In Canada, food packaging must meet the safety provisions of Division 23 of the Food and Drug Regulations. Health Canada explains that food sellers are responsible for ensuring packaging is safe for its intended use. Materials can be submitted voluntarily for a premarket chemical-safety assessment.
A statement on intentional PFAS addition does not replace food-contact review. Conversely, food-contact documentation does not necessarily answer every PFAS question. Procurement files should treat the two as related but distinct workstreams.
Write a specification that can be verified
A practical specification identifies the product scope, defines “intentionally added,” states required declarations or testing, sets reporting expectations, identifies applicable jurisdictions, and requires notification before relevant changes. Legal and technical teams should review wording for the buyer’s actual market.
Avoid treating a marketing logo or short supplier claim as the complete evidence package. The objective is a traceable statement that can be connected to a defined product, formulation, date, and commercial decision.
How RevivePack handles the conversation
RevivePack uses “no intentionally added PFAS” to describe a current formulation direction where documentation supports it. Format-specific documentation remains part of development and commercial evaluation. RevivePack does not use the phrase as an absolute environmental or certification claim.
Buyers can describe their documentation requirements at the start of an inquiry. That allows the relevance of a format and the available evidence to be reviewed before a sample or pilot decision.
Sources and further reading
- Government of Canada: State of PFAS Report
- Government of Canada: PFAS Risk Management Approach
- Health Canada: Packaging Materials
This article provides general commercial information and is not legal or regulatory advice.